NIOSH STATEMENT OF POLICY: 

MANAGEMENT OF CONFLICT OR BIAS IN THE RADIATION DOSE 

RECONSTRUCTION PROGRAM 

Rev 0 Issue Date: October 17, 2006 

Rev 1 Issue Date: June 3, 2008 

Rev 2 Issue Date: June 24, 2009 

______[Signature on File]_______ 

Christine M. Branche, Ph.D. 

Acting Director, National Institute for Occupational Safety and Health 

1.0 PURPOSE 

This document is a Statement of Policy1

 ("Policy") by the National Institute for 

Occupational Safety and Health (NIOSH) about conflicts or bias2

 (COB) of those 

persons and corporate entities disseminating scientific information as a part of 

the NIOSH Dose Reconstruction Program (Program). 

Disclosure and exclusion of COB ensures and maximizes the quality, objectivity, 

utility and integrity of all scientific information disseminated by the Program.3

 

Achieving the highest level of scientific information quality is a core value of the 

President's Office of Management and Budget4

 and the U.S. Department of 

Health and Human Services.5

 

Thus, it is crucial for Program integrity that each employee and corporate entity 

who performs any key Program function (Section 5.0) or Program support 

function (Section 6.0) disclose fully all past, current or planned future 

employment-related relationships, financial relationships, familial relationships, or 

supervisory or subordinate work relationships that could pose a COB. If such a 

COB is found, the individual or corporate entity is to be excluded from performing 

a key Program function for that site. 

 

1

 This Statement of Policy is not intended to and does not create any right or benefit, substantive or 

procedural, enforceable at law or in equity, against the United States, its agencies or other entities, its 

officers, employees or any other such person. 

2

 A "conflict or bias" means a potential, actual, or an appearance of a conflict and/or bias between the 

obligations of a person as a Program employee or contractor, and a personal or corporate interest. This 

Policy does not use the term "conflict of interest" as defined in 18 U.S.C. § 208 et seq.

3

 Information Quality Act, Pub. L. No. 106-554, § 1(a) (3)[Title V, § 515](Dec. 21, 2000)(published at 44 

U.S.C. § 3516 note). 

4

 "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information 

Disseminated by Federal Agencies.” See http://www.whitehouse.gov/fedreg/print/reproducible.html. 

5

 "HHS Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility and Integrity of 

Information Disseminated to the Public." See http://aspe.hhs.gov/infoquality/Guidelines/inde.shtml. 
2 

This COB Policy Statement balances two competing values: ensuring all relevant 

information is gathered regardless of source, and developing key Program 

documents of the highest scientific quality. 

First, NIOSH wants to ensure that it obtains all available factual information from 

all relevant sources about radiation doses received by workers having potential 

benefits under the Energy Employees Occupational Illness Compensation 

Program Act of 2000 (EEOICPA), including those individuals having any past or 

current employment-related relationships, financial relationships, familial 

relationships, or supervisory or subordinate work relationships with the 

Department of Energy (DOE), an Atomic Weapons Employer (AWE), contract 

operators of DOE facilities, or with other parties having a stake in the general or 

particular outputs or outcomes of the Program. 

Second, NIOSH wants to ensure that all scientific judgments contained in key 

Program function documents made by NIOSH employees or contractor 

employees about dose reconstruction are free from COB. 

NIOSH’s COB Policy Statement is posted and will be updated on the NIOSH 

Web site at the following locations on the web: Under information about Dose 

Reconstruction activities at http://www.cdc.gov/niosh/ocas/ocasdose.html and 

under information About OCAS at http://www.cdc.gov/niosh/ocas/ocasabt.html. 

NIOSH reserves the right to amend this COB Policy at any time to take account 

of changed facts and circumstances. 

2.0 COVERED ENTITIES 

Scientific information disseminated by the Program is generated by both NIOSH6

and by contractors.7

 If NIOSH cannot ensure the quality, objectivity, utility, and 

integrity of the scientific information contained in key Program documents, 

because of the occurrence of COB in those who generate the documents, those 

documents cannot be disseminated and the Program purposes cannot be carried 

out. Thus, NIOSH believes that the disclosure and exclusion provisions of this 

COB Policy Statement apply to all persons and corporate entities disseminating 

scientific information as a part of the Program. 

Exceptions: 

2.1 This Statement of Policy does not apply to members of the Advisory Board on 

Radiation and Worker Health (“ABRWH” or "Board"), who are appointed by, and 

serve at, the pleasure of the President. Board conduct is governed by applicable 

ethics standards contained in, among other sources, the criminal conflict of 

interest statutes and the administrative standards of ethical conduct. 

 

2.2 This Statement of Policy also does not apply to any federal contractor, and its 

subcontractors, whose work for the Program is in support of the Board’s review 

of the NIOSH dose reconstruction program under EEOICPA (i.e., the Board's

 

6

 "NIOSH" includes individuals working on Program-related duties in the NIOSH Office of the Director (OD), 

the NIOSH Office of Compensation Analysis and Support (OCAS). 

7

 "Contractor" refers to any entity and its employees who have a contractual obligation to provide services to 

the U.S. Department of Health and Human Services related to radiation dose reconstruction. 
3 

"review contractor”). Those entities will conform to applicable ethics-related 

restrictions contained in, among other sources, the Federal Acquisition 

Regulation (FAR) and the CDC contract governing the work, and are strongly 

encouraged to utilize the provisions of the NIOSH COB Policy Statement as a 

minimum standard. 

3.0 DISCLOSURE AND EXCLUSION 

3.1 Disclosure 

All individuals and corporate8

 entities performing any key Program 

function and any Program support function as set forth in Sections 5.0 

and 6.0 are required to disclose fully all past, current or planned future 

employment-related relationships, financial relationships, familial 

relationships, or supervisory or subordinate work relationships that could 

pose a COB by providing answers to the questions in the COB Disclosure 

Form (Appendix II) at the following times: 

• When the NIOSH COB Policy Statement is first implemented or when 

a new revision is implemented that substantially changes COB 

disclosure requirements; 

• When first hired; and 

• When a change occurs in an employment-related, financial, familial, 

or supervisory or subordinate work relationship that may pose a COB. 

3.2 Exclusion 

The existence of a COB excludes the individual or corporate entity from 

performing a Key Program Function associated with a site where a COB 

exists.9

 Persons or entities excluded from performing a key Program 

function may perform a Program support function after disclosing the 

COB. 

4.0 IDENTIFYING CONFLICT OR BIAS 

The following 12 questions are designed to assist covered entities in determining 

whether a COB may exist arising from a past, current or planned employmentrelated, financial, familial and/or a supervisory relationship. Question 4.1 

pertains to covered individuals only; all other questions pertain to covered 

individuals and corporate entities. Questions 4.2 through 4.10 speak to 

employment-related relationships between the covered entity and the 

 

8

 This COB Policy Statement applies not only to individuals performing Program-related duties, but also to 

their employers. Therefore, all such employers shall disclose to NIOSH any past, present, or planned future 

contracts with or for DOE, AWEs, DOE and AWE contractors, Department of Defense (DOD), or other 

departments and agencies of the federal government that involve the management, direction, or 

implementation of radiation protection and/or health physics program policies, practices or procedures; or 

that involve DOE- or other federal government agency-funded or -directed dose assessments, 

reconstructions, or related duties for individual workers at or for a DOE, AWE or other federally-owned or -

operated site. 

9 Key Program functions are described in Section 5.0 of this document. 
4 

Department of Energy (DOE), Atomic Weapons Employer (AWE) or DOE or 

AWE site operator, and questions 4.11 through 4.12 relate to financial, familial 

and subordinate relationships.

4.1 Are you10 currently engaged in any capacity (paid or unpaid) by the 

U.S. Department of Energy (DOE)? 

 If yes, a COB exists and the individual with the COB cannot 

 perform any key Program function for any site.11 If no, proceed to 

 Question 4.2. 

4.2 Do you, or did you, work12 either at or for this DOE or Atomic 

Weapons Employer (AWE) site? 

 If yes, a COB exists and the individual with the COB cannot perform a key 

 Program function related to that site. If no, proceed to Question 4.3. 

4.3 Do you, or did you, work for any of the past or current operators13 of 

 this site? 

 If yes, then proceed to Question 4.4. If no, then proceed to Question 4.6. 

4.4 During the time you worked for that operator, was that operator 

 responsible for this site? 

 If yes, then proceed to Question 4.5. If no, then proceed to Question 4.6. 

4.5 Did your work for the operator have an impact14 on this site? 

 If yes, then a COB exists and the individual with the COB cannot perform 

 a key Program function for that site. If no, then proceed to Question 4.6. 

 4.6 Did you work for DOE in the past15? 

 

10The term “you” used in question 4.1 includes just individuals. It includes both individuals and corporate 

entities for questions 4.2 through 4.12. 

11 “Site” and “facility” are defined to include DOE, AWE, and other federally-owned or -operated sites. For 

purposes of brevity, the "other federally-owned or -operated sites" category shall be referred to in this 

document as “other” sites. 

12 "Work" means employment at or for the site, site contractor, or site subcontractor that includes 

management, direction, or implementation of radiation protection and/or health physics program policies, 

procedures or practices related to atomic weapons activities at the site. 

13 "Operator" refers to the governmental and/or corporate entities, including their subcontractors, responsible 

for performing and overseeing day-to-day work activities at the site. 

14 "Impact" means that your work involved decision-making authority over management, direction, or 

implementation of radiation protection and/or health physics program policies, procedures, or practices 

related to atomic weapons activities at the site. 
5 

 If yes, then proceed to Question 4.7. If no, then proceed to Question 

 4.9. 

4.7 Did the time period you worked for DOE overlap at all with the 

covered period of this site? 

If yes, then proceed to Question 4.8. If no, then proceed to Question 4.9. 

4.8 Did your work for DOE have an impact on this site? 

If yes, then a COB exists and the individual with the COB cannot perform 

a key Program function for that site. If no, then proceed to Question 4.9. 

 4.9 Do you have a familial relationship16 or subordinate 

 work relationship17 with an EEOICPA claimant whose claim involves 

 this site? 

 If yes, then a COB exists and the individual with the COB cannot perform 

 a key Program function for the site or sites. If no, then proceed to 

 Question 4.10. 

4.10 Do you have a familial relationship or subordinate work relationship 

with anyone who has had an impact on this site? 

 If yes, then proceed to Question 4.11. If no, then proceed to Question 

 4.12.

4.11 If you have a subordinate relationship to someone who has or had 

an impact on the site, has a different person been designated to 

review your job performance as it relates to the site? 

 If no, then a COB exists and the individual with the COB cannot perform a 

key Program function for the site or sites. If yes, then proceed to 

Question 4.12. 

 4.12 Do or did you have a familial, financial or non- 

 financial professional (e.g., providing expert advice) relationship 

 with any attorney at the time the attorney represented an EEOICPA 

 claimant, DOE or operator? 

 15 "Work for DOE in the past" does not include work for DOE of less than four months’ continuous duration 

as a student intern, graduate fellow, or in another primarily educational capacity; it also does not include 

having received a financial stipend from DOE for graduate study, a fellowship in the context of an 

established DOE fellowship program intended to support graduate-level work, or receipt of a federal 

government retirement pension for prior DOE service. 

16 “Familial relationship” encompasses a current spouse, child, parent, sibling, or grandparent that worked at 

or for the site; or any survivors of a current spouse, child, parent, sibling, or grandparent that are eligible to 

file claims under the Program.

17 “Subordinate work relationship” is one where an individual is supervised by an individual with a COB who 

is within two organizational levels above the subordinate; and (b) where "work" is defined as in Footnote 12. 
6 

 If yes, then a COB exists and the individual with the COB cannot perform 

 a key Program function for that site. If no, then no COB exists and 

 the individual can perform a key Program function. 

5.0 KEY PROGRAM FUNCTIONS 

Note: Key Program functions are those activities that must be performed by 

individuals who do not have a COB as defined in the questions set forth in 

Section 4.0. Because the questions in Section 4.0 relate to both key Program 

functions and covered sites, it is important that disclosure of COB relate to a 

covered site. It is acceptable, then, to exclude a covered entity who discloses a 

COB in Section 4.0 from performing any and all key Program functions for that 

site regardless of the period during which he was conflicted or biased at the site. 

5.1 Document Approval Authority 

The Document Approval Authority exercises approval authority by 

signature to permit use by the Program of a Dose Reconstruction Report, 

Site Profile Document, SEC Petition Evaluation Report, Site-Specific and 

Multiple-Site Technical Information Bulletin (TIB), and any other key 

Program function document created for use by the Program. Any 

exercise of such approval authority is treated as a key Program function 

under this policy, and the individual who exercises that authority shall 

ensure that the exclusions and attributions required by this COB Policy 

Statement have been met before signing the document and approving it 

for use in the Program. 

5.2 Dose Reconstructionist 

A Dose Reconstructionist is responsible for conducting dose 

reconstructions for the Program which include, but are not limited to, 

analyzing monitoring methods, performing uncertainty analyses, 

estimating organ or effective dose from available monitoring data, and 

incorporating any comments from Dose Reconstruction Report 

Reviewers. A Dose Reconstructionist is responsible for any and all 

revisions to a Dose Reconstruction Report. 

5.3 Dose Reconstruction Report Peer Reviewer 

A Dose Reconstruction Report Peer Reviewer is responsible for 

conducting a review of the Dose Reconstruction Report to ensure that all 

appropriate sources of information for possible doses are included and 

that all calculations are accurate. 

5.4 NIOSH COB Officer

The NIOSH COB Officer, who reports directly to the NIOSH Director, is 

responsible for ensuring that any key Program function document 

disseminated by NIOSH conforms substantively and procedurally to all 

the provisions contained in this COB Policy Statement. In addition, the 
7 

COB Officer manages the process to ensure that all key Program function 

documents conform to the NIOSH COB Policy Statement. For example, 

the COB Officer will review all disclosures; investigate and resolve 

complaints about failure to disclose; may examine key Program 

documents for proper attribution; and examine the roles of the document 

owner, site, and subject experts in key Program documents. 

5.5 Site Profile Document Owner 

A Site Profile Document18 Owner is responsible for coordinating and 

drafting all Site Profile Documents, ensuring that all relevant information 

is captured in the document, evaluating information, and establishing or 

setting forth specific findings or conclusions. The Site Profile Document 

Owner is the primary writer/editor of the Site Profile Document. The Site 

Profile Document Owner has an affirmative duty to seek out all relevant 

data and to objectively evaluate all relevant input with no special 

consideration given due to the source (e.g., site expert or subject expert). 

All narrative or quantitative input to Site Profile Documents shall be 

clearly attributed19 to each source(s) wherever it appears or is relied upon 

within a Site Profile document. In addition, both Site and Subject Experts 

shall be clearly identified on the approval page of every Site Profile 

Document to which they contributed. A Site Profile Document Owner is 

responsible for any and all revisions to a Site Profile Document. 

5.6 Site-Specific Technical Information Bulletin Owner 

A Site-Specific Technical Information Bulletin Owner is responsible 

for coordinating and drafting a TIB which addresses a technical issue or 

concern regarding dose reconstructions for a specific exposure that may 

occur at one or more specific DOE or AWE facilities20, ensuring that all 

relevant information is captured in the document, evaluating information, 

and establishing or setting forth a specific approach to resolve the 

technical issue or concern. The Site-Specific TIB Owner is the primary 

writer/editor of the subject TIB. The Site-Specific TIB Owner has an 

affirmative duty to seek out all relevant information, and to objectively 

evaluate all relevant input with no special consideration given due to the 

source (e.g., site expert or subject expert). 

All narrative or quantitative input to a Site-Specific TIB shall be clearly 

attributed to each source(s) wherever it appears or is relied upon within a 

TIB. The specific DOE or AWE site to which the TIB applies shall be 

 

18 "Site profile document" also includes any "Technical Basis Documents," or TBDs, related to the site. 

19 "Attributed” means the inclusion of footnotes, endnotes, a list of references, or other markings to identify 

the person, organization, or document sources for information in Program documents. The level of 

specificity of the attribution shall be appropriate to the importance of the information and may include, for 

example, document sections, paragraphs, tables or figures, or other key components of the document. 

20 “Site-Specific” TIB is one that applies to a single site, or a limited number of sites where those sites are 

identified by name in the document.
8 

listed in the TIB. In addition, both Site and Subject Experts shall be 

clearly identified on the approval page of every Site-Specific TIB to which 

they contributed. A Site-Specific Technical Information Bulletin Owner is 

responsible for any and all revisions to a Site-Specific TIB. 

5.7 Special Exposure Cohort Petition Evaluation Report 

 Owner 

A Special Exposure Cohort (SEC) Petition Evaluation Report Owner

is responsible for leading and documenting the evaluation of a qualified 

SEC petition to determine the feasibility of performing dose 

reconstruction. This individual is the primary writer/editor of the SEC 

Petition Evaluation Report. The SEC Petition Evaluation Report Owner 

has an affirmative duty to seek out all relevant data and to objectively 

evaluate all relevant input with no special consideration given due to the 

source (e.g., site expert or subject expert). 

All narrative or quantitative input to SEC Petition Evaluation Reports shall 

be clearly attributed to each source(s) wherever it appears or is relied 

upon within the SEC Petition Evaluation Report. In addition, both Site 

and Subject Experts shall be clearly identified on the approval page of 

every SEC Petition Evaluation Report to which they contributed. A SEC 

Petition Evaluation Report Owner is responsible for any and all revisions 

to an SEC Petition Evaluation Report. 

6.0 PROGRAM SUPPORT FUNCTIONS 

6.1 Implementation Guide Owner 

An Implementation Guide Owner is responsible for providing basic 

guidelines on the general methods employed in reconstructing either 

internal or eternal doses. These methods acknowledge the claim-specific 

circumstances that may require a best estimate of dose, or for efficiency 

purposes, an underestimate or an overestimate of the actual radiation 

dose received. The Implementation Guide Owner is the primary 

writer/editor of the Implementation Guide and is responsible for 

coordinating and drafting the Implementation Guide. The Implementation 

Guide Owner has an affirmative duty to seek out all relevant information, 

and to objectively evaluate all relevant input with no special consideration 

given due to the source (e.g., site expert or subject expert). 

6.2 Multiple-Site Technical Information Bulletin Owner 

A Multiple-Site Technical Information Bulletin Owner is responsible 

for coordinating and drafting a TIB which addresses a technical issue or 

concern regarding dose reconstructions for a specific exposure that may 

occur at multiple DOE or at AWE facilities21, ensuring that all relevant 

information is captured in the document, evaluating information, and 

establishing or setting forth a specific approach to resolve the technical 

 

21 A “multiple-site” TIB is one that applies in a generic fashion to a number of sites that are not designated as 

such in the document.
9 

issue or concern. The Multiple-Site TIB Owner is the primary writer/editor 

of the TIB. The Multiple-Site TIB Owner has an affirmative duty to seek 

out all relevant information, and to objectively evaluate all relevant input 

with no special consideration given due to the source (e.g., site expert or 

subject expert). All narrative or quantitative input to a Multiple-Site TIB 

shall be clearly attributed to each source(s) wherever it appears or is 

relied upon within such a TIB. Each DOE or AWE site to which the TIB 

applies shall be listed in the TIB. In addition, both Site and Subject 

Experts shall be clearly identified on the approval page of every TIB to 

which they contributed. A Multiple-Site Technical Information Bulletin 

Document Owner is responsible for any and all revisions to a Multiple-Site 

TIB. 

6.3 Scientific/Technical Peer Reviewer 

A Scientific/Technical Peer Reviewer is responsible for conducting a 

scientific and technical review of the key Program documents (e.g., Dose 

Reconstruction Report, Site Profile Document, SEC Petition Evaluation 

Report, Site-Specific or Multiple-Site TIB), and any other Program 

document created for use by the Program. 

6.4 Site Expert 

A Site Expert is responsible for advising on site-specific issues and 

 incidents as necessary to ensure the completeness and accuracy of 

 Site Profile Documents and Special Exposure Cohort Petition Evaluation 

 Reports. Site Experts are those individuals who, because of current or 

 prior work experience (including consulting) at or for the site, possess or 

 are aware of information that is relevant for reconstructing radiation doses 

 experienced by claimants who worked at the site. 

Because of their work experience at or for sites under Program review 

and the need to prevent COB, site experts shall play only a very limited 

role in accomplishing key Program functions. They may be used by a 

document owner in crafting a key Program document, to provide both 

data and opinions on data to that document owner. In all cases where 

such information or prior studies or writings are included or relied upon by 

a key Program document owner, those materials shall be both fully 

attributed to the Site Expert and reprinted, if at all, only in an Appendix of 

the key Program document. 

Site Experts are not permitted to serve as document owners or authors, 

or to make formal public presentations on a key Program document. 

However, at a formal public presentation, a Site Expert may be called 

upon to answer questions and serve as a source of information to the 

presenter in response to questions that arise during a presentation. 

6.5 Subject Expert 

A Subject Expert is responsible for advising on scientific and technical 

issues and incidents as necessary to ensure the completeness and 
10 

accuracy of Site Profile Documents and SEC Petition Evaluation Reports. 

In contrast with Site Experts, Subject Experts are those individuals who 

have expertise in the subject matter of the activities performed at the site, 

but do not have any current or prior work experience at or for the subject 

site itself. 

7.0 COMPLIANCE 

7.1 Procedures

All covered entities are required to demonstrate to NIOSH that they are 

complying with the COB Policy Statement. Each covered entity, through 

its Contract Officer or designee, shall: 

(a) Post on its website, within sixty (60) days of final publication of the 

 COB Policy, and within 60 days of any subsequent revisions, its 

 own procedures demonstrating compliance with the COB Policy; 

(b) Require that its Contract Officer inform the entity’s employees of 

 the COB Policy and the entity's procedures implementing the 

 Policy, and ensure that each employee and the corporate entity 

 complete the COB Disclosure Form or its equivalent; 

(c) Post on its website, with a link on the NIOSH website, an 

 electronic copy of all completed individual and corporate COB 

 Disclosure Forms within two days of completion (subject to 

 redaction as needed to comply with the Privacy Act and to protect 

 trade secrets and other "business confidential" information of the 

 type permitted to be withheld from disclosure by the Freedom of 

 Information Act); and 

(d) Ensure that information on the COB Disclosure Form is 

 updated according to Section 3.0. 

7.2 Verification of Adherence to Information Quality 

Verification of NIOSH employee and federal contractor COB disclosures 

shall be the responsibility of NIOSH and each federal contractor, 

respectively. To ensure greater compliance and accuracy, NIOSH will 

audit the completed COB Disclosure Forms periodically as a quality 

assurance measure. Any errors discovered in forms filed at or after the 

time this COB Policy Statement takes effect shall be corrected 

immediately at the filing employer’s or contractor’s expense. The cost to 

remediate errors discovered in forms filed prior to this COB Policy taking 

effect shall be determined on a case-by-case basis. Such corrective 

actions may include, but are not limited to, filing corrected forms, 

transferring or removing workers found to have exclusionary conflicts, and 

redrafting and/or re-reviewing documents as needed. 

If a federal employer, federal contractor, federal employee, EEOICPA 

claimant, member of the general public, or any other person, wishes to 

submit a complaint regarding a missing or erroneous disclosure, that 
11 

party may do so by calling the NIOSH COB Officer at 1-800-CDC-INFO1-

800-232-4636). 

7.3 Contract Obligations Related to Information Quality 

Failure by a contractor and/or its employee(s) to comply with this COB 

policy renders the scientific information generated by the contractor 

unable to be disseminated by NIOSH. Failure to generate utilizable 

scientific information may result in penalties including, but not limited to, 

removal of the contractor itself and/or the employees of a contractor from 

employment in the Program, reduction in contract payments, and/or 

termination of contracts, as determined by NIOSH. 

NIOSH intends that the provisions of this COB Policy Statement be 

incorporated as a contract provision for all covered entities and tracked as 

a contract deliverable and is pursuing that aspect of implementation with 

the CDC Procurement and Grants (PGO) Office. 

7.4 Compliance Information Contacts

All questions from individuals and employers regarding compliance with 

this COB Policy should first be directed to the respective employer’s COB 

manager or person with equivalent responsibilities. 

Questions may also be directed to the NIOSH COB Officer at CDCINFO1-800-232-4636). In the event of a dispute between NIOSH and an 

employee or contactor, NIOSH alone shall make the final decision on any 

question of compliance. 
12 

Appendix I 

Advisory Board on Radiation and Worker Health 

42 U.S.C. § 7384o establishes the Advisory Board on Radiation and Worker Health ("ABRWH" or 

"Board") and grants the President the power to appoint individual members "in consultation with 

organizations with expertise on worker health issues in order to ensure that the membership of 

the Board reflects a balance of scientific, medical, and worker perspectives." 

The enumerated duties of members of the Board include developing guidelines for performing 

technical reviews; providing advice on the scientific validity and quality of dose estimation and 

reconstruction efforts being performed for the Program; and advising on other relevant Program 

matters. Specifically, Board members perform many key Program functions, e.g., review of Dose 

Reconstruction Reports, Site Profile Documents and SEC Petition Evaluation Reports. Board 

conduct is governed by applicable ethics standards contained in, among other sources, the 

criminal conflict of interest statutes and the administrative standards of ethical conduct. NIOSH 

recommends that the Board supplement those restrictions by making provisions for disclosure 

and exclusion, to ensure that its decisions are, to the maximum extent possible, free of any actual 

or perceived conflict or bias. 

Note: On August 8, 2006, the Board approved the original version of the NIOSH COB policy, 

including the original Appendix I. HHS and NIOSH are currently reviewing Appendix I. The 

language under review has been removed at this time. NIOSH will revise Appendix I to reflect the 

outcome of the review. 
13 

Appendix II -- Conflict or Bias Disclosure Form 

Section A. Identification 

1. Name of Individual or Corporate Entity: _______________________________________ 

2. Name of Employer: _______________________ 3. Today's Date: _________ 

Section B. Program Function Assignments. 

Check all key Program functions and Program support functions which you (or your 

employees, if you are a corporate entity) perform. 

Note: It is acceptable to base COB on site rather than key Program or Program Support 

function. Using this approach, the designation of the key Program functions and Program 

Support functions is not necessary because a COB individual will be prohibited from 

performing all key program functions for that site regardless of the period during which he 

was conflicted or biased at the site. 

Key Program Functions: 

□ Document Approval and Review Authority 

□ Dose Reconstructionist 

□ Dose Reconstruction Report Reviewer 

□ NIOSH COB Officer 

□ Site Profile Document Owner 

□ Site-Specific Technical Information Bulletin Owner 

□ Special Exposure Cohort Petition Evaluation Document Owner 

Program Support Functions: 

□ Implementation Guide Owner 

□ Multi-Site Technical Information Bulletin Owner 

□ Scientific/Technical Peer Reviewer 

□ Site Expert 

□ Subject Expert 

Section C. Questions to Identify a Conflict or Bias 

1. Are you22 currently engaged in any capacity (paid or unpaid) by the U.S. Department of 

Energy (DOE)? Check Yes or No. 

Yes _______, a COB exists; please check in Section D. each DOE location at which you are 

currently engaged, then and proceed to Section E. If No ________, proceed to Question 2. 

 

22 The term “you” used in question 1 includes just individuals. It includes both individuals and corporate 

entities for questions 4.2 through 12.
14 

2. Do you, or did you, work either at or for this DOE or Atomic Weapons Employer (AWE) 

site? Check Yes or No. 

Yes _______, a COB exists; please check in Section D. each relevant DOE or AWE and then 

proceed to Section E. If No ________, proceed to Question 3. 

3. Do you, or did you, work for any of the past or current operators of this site? Check Yes 

or No. 

Yes _______, a COB exists; please check in Section D. each relevant DOE or AWE site, indicate 

below the names of the operators, and then proceed to Section E. If No ________, proceed to 

Question 6. 

________________________________________________________________

________________________________________________________________

________________________________________________________________

4. During the time you worked for that operator, was that operator responsible for this 

site? Check Yes or No. 

If Yes _______, proceed to Question 5. If No ________, proceed to Question 6. 

5. Did your work for the operator have an impact on this site? Check Yes or No. 

If Yes _______, a COB exists. Please provide details about the nature of the impact your work for 

the operator had on the site and then proceed to Section E. If No ________, proceed to 

Question 6. 

________________________________________________________________

________________________________________________________________

________________________________________________________________ 

6. Did you work for DOE in the past? Check Yes or No. 

If yes ____, please check in Section D. each DOE location at which you worked in the past, then 

and proceed to Question 7. If No ____________, proceed to Question 9. 

7. Did the time period you worked for DOE overlap at all with the covered period of this 

site? Check Yes or No. 

If Yes _______ please specify both the exact (starting and stopping) dates of your employment at 

DOE and the time periods covered by the key Program function document. Then, please 

proceed to Question 8. If No __________, then proceed to Question 9. 

________________________________________________________________

________________________________________________________________

________________________________________________________________ 

8. Did your work for DOE have an impact on this site? Check Yes or No. 

If Yes _______, then a COB exists. Please provide details about the nature of the impact your 

work for the operator had on the site and then proceed to Section D. If No ____, then proceed to 

Question 9. 
15 

________________________________________________________________

________________________________________________________________

________________________________________________________________

9. Do you have a familial relationship or a subordinate work relationship with an EEOICPA 

claimant whose claim involves this site? Check Yes or No. 

If Yes ______, then a COB exists. Proceed to Section D. If No ______, then proceed to 

Question 10. 

________________________________________________________________

________________________________________________________________

________________________________________________________________

10. Do you have a familial relationship or subordinate work relationship with anyone who 

has had an impact related to this site? Check Yes or No. 

If Yes ______, then proceed to Question 11. If No ________, then proceed to Question 12. 

11. If you have a subordinate relationship to someone who has (had) an impact on this 

site, has a different person been designated to review your job performance as it relates to 

the site? Check Yes or No. 

If Yes ____, a COB does not exist. Proceed to Section E. If No ______, then a COB exists. 

________________________________________________________________

________________________________________________________________

________________________________________________________________

12. Do or did you have a familial, financial or non-financial professional (e.g., providing 

expert advice) relationship with any attorney at the time the attorney represented an 

EEOICPA claimant, DOE or the operator? 

If Yes _______, then a COB exists. Please provide details about the relationship with the 

attorney, to include (if applicable) a list of cases for which you assisted the attorney as well as the 

names of parties on whose behalf you testified or otherwise provided assistance and then 

proceed to Section E. If No, _____, then a COB does not exist. 

________________________________________________________________

________________________________________________________________

________________________________________________________________ 
16 

Section D. Covered Sites Under EEOICPA

Please indicate next to the name of each site either "COB," which means you may have a conflict 

or bias at that particular site (based on your answers to the Questions in Section C.), or an "N/A" 

which means you do not believe that you have a COB at that particular site. Any details can be 

added at the end of Section D. 

"COB" 

or 

"N/A" 

Your Name: Date: 

 Covered Site City State

AC Spark Plug Flint MI 

AMCOT Fort Worth TX 

Aeroprojects, Inc. West Chester PA 

Aja Magnathermic Corp. Youngstown OH 

Alba Craft Oxford OH 

Albany Research Center Albany OR 

Albuquerque Operations Office Albuquerque NM 

Aliquippa Forge Aliquippa PA 

Allegheny-Ludlum Steel Watervliet NY 

Allied Chemical Corp. Plant Metropolis IL 

Allied Chemical and Dye Corp. North Claymont DE 

Allis-Chalmers Co. 

West Allis, 

Milwaukee WI 

Aluminum Co. of America (Alcoa) 1 New Kensington PA 

Aluminum Co. of America (Alcoa) 2 Garwood NJ 

Amchitka Island Nuclear Explosion Site Amchitka Island AK 

American Bearing Corp. Indianapolis IN 

American Chain and Cable Co. Bridgeport CT 

American Machine and Foundry Brooklyn NY 

American Machine and Metals, Inc. E. Moline IL 

American Peddinghaus Corp. Moonachle NJ 

American Potash & Chemical West Hanover MA 

Ames Laboratory Ames IA 

Anaconda Co. Waterbury CT 

Argonne National Laboratory – East Argonne IL 

Argonne National Laboratory – West Scoville ID 

Armco-Rustless Iron and Steel Baltimore MD 

Armour Fertilizer Works Bartow FL 

Armour Research Foundation Chicago IL 

Arthur D. Little Co. San Francisco CA 

Ashland Oil Tonawanda NY 

Associated Aircraft Tool and Manufacturing Co. Fairfield OH 

B & T Metals Columbus OH 

BONUS Reactor Plant Punta Higuera PR 

BWT Lynchburg VA 

Baker Brothers Toledo OH 
17 

Baker and Company Newark NJ 

Baker and Williams Warehouses New York NY 

Baker-Perkins Co. Saginaw MI 

Battelle Laboratories - King Avenue Columbus OH 

Battelle Laboratories - West Jefferson Columbus OH 

Bell Telephone Laboratories Murray Hill NJ 

Bendi Aviation (Pioneer Division) Davenport IA 

Beryllium Production Plant (Brush) Luckey OH 

Besley-Wells South Beloit WI 

Bethlehem Steel Lackawanna NY 

Birdsboro Steel & Foundry Birdsboro PA 

Bliss & Laughlin Steel Buffalo NY 

Blockson Chemical Co. (Building 55 and related activities) Joliet IL 

Bloomfield Tool Co. Bloomfield NJ 

Bowen Engineering, Inc. North Branch NJ 

Bridgeport Brass Co., Adrian Adrian MI 

Bridgeport Brass Co., Havens Lab Bridgeport CT 

Brookhaven National Laboratory Upton NY 

Brush Beryllium Co. 1 Detroit MI 

Brush Beryllium Co. 4 Cleveland OH 

C - B Tool Products Co. Chicago IL 

C. G. Sargent & Sons Graniteville MA 

C. H. Schnorr Springdale PA 

C. I. Hayes, Inc. Cranston RI 

California Research Corp. Richmond CA 

Callite Tungsten Co. Union City NJ 

Carboloy Co. Detroit MI 

Carnegie Institute of Technology Pittsburgh PA 

Carpenter Steel Co. Reading PA 

Chambersburg Engineering Co. Chambersburg PA 

Chapman Valve Indian Orchard MA 

Chemical Construction Co. Linden NJ 

Chupadera Mesa 

Chupadera 

Mesa NM 

Cincinnati Milling Machine Co. Cincinnati OH 

Clarksville Facility Clarksville TN 

Colonie Site (National Lead) Colonie (Albany) NY 

SAM Laboratories, Columbia University New York City NY 

Combustion Engineering Windsor CT 

Connecticut Aircraft Nuclear Engine Laboratory Middletown CT 

Copperweld Steel Warren OH 

Crane Co. Chicago IL 

Crucible Steel Co. Syracuse NY 

Dana Heavy Water Plant Dana IN 

Dorr Corp. Stamford CT 

Dow Chemical Co. Walnut Creek CA 
18 

Du Pont - Grasselli Research Laboratory Cleveland OH 

Du Pont Deepwater Works Deepwater NJ 

ERA Tool and Engineering Co. Chicago IL 

Edgerton Germeshausen & Grier, Inc. Boston MA 

Electro Circuits, Inc. Pasadena CA 

Electro Metallurgical Niagara Falls NY 

Elk River Reactor Elk River MN 

Area IV of the Santa Susana Field Laboratory Santa Susana CA 

Environmental Measurements Laboratory New York NY 

Extruded Metals Co. Grand Rapids MI 

Extrusion Plant (Reactive Metals Inc.) Ashtabula OH 

Feed Materials Production Center (FMPC) Fernald OH 

Fenn Machinery Co. Hartford CT 

Fenwal, Inc. Ashland MA 

Fermi National Accelerator Laboratory Batavia IL 

Foote Mineral Co. 

East Whiteland 

Twp. PA 

GSA 39th Street Warehouse Chicago IL 

Gardinier, Inc. Tampa FL 

General Atomics La Jolla CA 

General Electric Company 

Cincinnati / 

Evendale OH 

General Electric Plant Shelbyville IN 

General Electric Vallecitos Pleasanton CA 

Grand Junction Operations Office Grand Junction CO 

General Steel Industries Granite City IL 

Great Lakes Carbon Corp. Chicago IL 

Gruen Watch Norwood OH 

Hallam Sodium Graphite Reactor Hallam NE 

Hanford Richland WA 

Harshaw Chemical Co. Cleveland OH 

Heald Machine Co. Worcester MA 

Heppenstall Co. Pittsburgh PA 

Herring - Hall Marvin Safe Co. Hamilton OH 

Hooker Electrochemical Niagara Falls NY 

Horizons, Inc. Cleveland OH 

Hunter Douglas Aluminum Corp. Riverside CA 

Huntington Pilot Plant Huntington WV 

Idaho National Laboratory Scoville ID 

International Minerals and Chemical Corp. Mulberry FL 

International Nickel Co., Bayonne Laboratories Bayonne NJ 

International Rare Metals Refinery, Inc. Mt. Kisco NY 

International Register Chicago IL 

Iowa Ordnance Plant Burlington IA 

Ithaca Gun Co. Ithaca NY 

J. T. Baker Chemical Co. Phillipsburg NJ 
19 

Jessop Steel Co. Washington PA 

Joslyn Manufacturing and Supply Co. Ft. Wayne IN 

Kaiser Aluminum Corp. Dalton IL 

Kansas City Plant Kansas City MO 

Kauai Test Facility Kauai HI 

Kelle/Pierpont Jersey City NJ 

Kerr – McGee Guthrie OK 

Koppers Co., Inc. Verona PA 

La Pointe Machine and Tool Co. Hudson MA 

LaCrosse Boiling Water Reactor LaCrosse WI 

Laboratory for Energy-Related Health Research Davis CA 

Laboratory of Biomedical and Environmental Sciences Los Angeles CA 

Laboratory of Radiobiology and Environmental Health San Francisco CA 

Lake Ontario Ordnance Works Niagara Falls NY 

Landis Machine Tool Co. Waynesboro PA 

Latty Avenue Properties Hazelwood MO 

Lawrence Berkeley National Laboratory Berkeley CA 

Lawrence Livermore National Laboratory Livermore CA 

Linde Air Products Buffalo NY 

Linde Ceramics Plant Tonawanda NY 

Lindsay Light and Chemical Co. W. Chicago IL 

Los Alamos Medical Center Los Alamos NM 

Los Alamos National Laboratory Los Alamos NM 

Lovelace Respiratory Research Institute Albuquerque NM 

DOW Chemical Co. (Madison Site) Madison IL 

Magnus Brass Co. Cincinnati OH 

Mallinckrodt Chemical Co., Destrehan St. Plant St. Louis MO 

Massachusetts Institute of Technology Cambridge MA 

Mathieson Chemical Co. Pasadena TX 

Maywood Chemical Works Maywood NJ 

McKinney Tool and Manufacturing Co. Cleveland OH 

Medart Co. St. Louis MO 

Medina Facility San Antonio TX 

Metals and Controls Corp Attleboro MA 

Middlesex Municipal Landfill Middlesex NJ 

Middlesex Sampling Plant Middlesex NJ 

Midwest Manufacturing Co. Galesburg IL 

Mitchell Steel Co. Cincinnati OH 

Mitts & Merrel Co. Saginaw MI 

Monsanto Chemical Co. Dayton OH 

Mound Plant Miamisburg OH 

Museum of Science and Industry Chicago IL 

National Bureau of Standards, Van Ness Street Washington DC 

National Guard Armory Chicago IL 

National Research Corp. Cambridge MA 

Naval Research Laboratory Washington DC 
20 

Nevada Test Site Mercury NV 

New Brunswick Laboratory New Brunswick NJ 

New England Lime Co. Canaan CT 

New York University New York NY 

Norton Co. Worcester MA 

Nuclear Materials and Equipment (NUMEC) - Parks Township Parks Township PA 

Nuclear Materials and Equipment Corp. (NUMEC) - Apollo Apollo PA 

Nuclear Metals, Inc. Concord MA 

Oak Ridge Gaseous Diffusion Plant (K-25) Oak Ridge TN 

Oak Ridge Hospital Oak Ridge TN 

Oak Ridge Institute for Science Education Oak Ridge TN 

Oak Ridge National Laboratory (X-10) Oak Ridge TN 

Oliver Corp. Battle Creek MI 

Pacific Northwest National Laboratory Richland WA 

Pacific Proving Ground Marshall Islands MH 

Paducah Gaseous Diffusion Plant Paducah KY 

Painsville Site (Diamond Magnesium Co.) Painsville OH 

Pantex Plant Amarillo TX 

Peek Street Facility Schenectady NY 

Penn Salt Co. 

Philadelphia / 

Wyndmoor PA 

Philadelphia Naval Yard Philadelphia PA 

Pinellas Plant Clearwater FL 

Piqua Organic Moderated Reactor Piqua OH 

Podbeliniac Corp. Chicago IL 

Portsmouth Gaseous Diffusion Plant Piketon OH 

Precision Extrusion Co. Bensenville IL 

Princeton Plasma Physics Laboratory Princeton NJ 

Project Chariot Site Cape Thompson AK 

Project Faultless Nuclear Explosion Site 

Central Nevada 

Test Site NV 

Project Gasbuggy Nuclear Explosion Site Farmington NM 

Project Gnome Nuclear explosion Site Carlsbad NM 

Project Rio Blanco Nuclear Explosion Site Rifle CO 

Project Rulison Nuclear Explosion Site Grand Valley CO 

Project Shoal Nuclear Explosion Site Fallon NV 

Puerto Rico Nuclear Center Mayaguez PR 

Purdue University Lafayette IN 

Quality Hardware and Machine Co. Chicago IL 

R. Krasburg and Sons Manufacturing Co. Chicago IL 

R. W. Leblond Machine Tool Co. Cincinnati OH 

Radium Chemical Co. New York NY 

Rare Earth/W. R. Grace Wayne NJ 

Reed Rolled Thread Co. Worcester MA 

Revere Copper and Brass Detroit MI 

Rocky Flats Plant Golden CO 
21 

Roger Iron Co. Joplin MO 

Sacandaga Facility Glenville NY 

Salmon Nuclear Explosion Site Hattiesburg MS 

Sandia Laboratory-Salton Sea Base Imperial County CA 

Sandia National Laboratory Albuquerque NM 

Sandia National Laboratories – Livermore Livermore CA 

Savannah River Site Aiken SC 

Sciaky Brothers, Inc. Chicago IL 

Seaway Industrial Park Tonawanda NY 

Separations Process Research Unit (at Knolls Lab) Schenectady NY 

Seymour Specialty Wire Seymour CT 

Shattuck Chemical Denver CO 

Shippingport Atomic Power Plant Shippingport PA 

Shpack Landfill Norton MA 

Simonds Saw and Steel Co. Lockport NY 

South Albuquerque Works Albuquerque NM 

Southern Research Institute Birmingham AL 

Spencer Chemical Co., Jayhawks Works Pittsburg KS 

Sperry Products, Inc. Danbury CT 

St Louis Airport Storage Site (SLAPS) St. Louis MO 

Standard Oil Development Co. of NJ Linden NJ 

Stanford Linear Accelerator Center Palo Alto CA 

Star Cutter Corp. Farmington MI 

Staten Island Warehouse New York NY 

Stauffer Metals, Inc. Richmond CA 

Superior Steel Co. Carnegie PA 

Sutton, Steele and Steele Co. Dallas TX 

Swenson Evaporator Co. Harvey IL 

Sylvania Corning Nuclear Corp - Bayside Laboratories Bayside NY 

Sylvania Corning Nuclear Corp - Hicksville Plant Hicksville NY 

Tech-Art, Inc. Milford OH 

Tennessee Valley Authority Muscle Shoals AL 

Texas City Chemicals, Inc. Texas City TX 

Thomas Jefferson National Accelerator Facility Newport News VA 

Titanium Alloys Manufacturing Niagara Falls NY 

Titus Metals Waterloo IA 

Tocco Induction Heating Div Cleveland OH 

Torrington Co. Torrington CT 

Trinity Nuclear Explosion Site White Sands NM 

Tube Reducing Co. Wallington NJ 

Tyson Valley Powder Farm St. Louis MO 

U.S. Steel Co., National Tube Division McKeesport PA 

United Lead Co. Middlesex NJ 

United Nuclear Corp. Hematite MO 

University of California Berkeley CA 

Metallurgical Laboratory Chicago IL 
22 

University of Denver Research Institute Denver CO 

University of Florida Gainesville FL 

University of Michigan Ann Arbor MI 

University of Rochester Atomic Energy Project Rochester NY 

University of Virginia Charlottesville VA 

Utica St. Warehouse Buffalo NY 

Ventron Corporation Beverly MA 

Virginia-Carolina Chemical Corp. Nichols FL 

Vitro Corp. of America, Chattanooga Chattanooga TN 

Vitro Corp. of America, West Orange West Orange NJ 

Vitro Manufacturing Canonsburg PA 

Vulcan Tool Co. Dayton OH 

W. E. Pratt Manufacturing Co. Joliet IL 

W. R. Grace Erwin TN 

W. R. Grace Co., Agricultural Chemical Div. Ridgewood FL 

W. R. Grace and Company Curtis Bay MD 

Wah Chang Albany OR 

Waste Isolation Pilot Plant Carlsbad NM 

Watertown Arsenal Watertown MA 

Weldon Spring Plant Weldon Spring MO 

West Valley Demonstration Project West Valley NY 

Westinghouse Atomic Power Development Plant East Pittsburgh PA 

Westinghouse Electric Corp. Bloomfield NJ 

Winchester Engineering and Analytical Center Winchester MA 

Woburn Landfill Woburn MA 

Wolff - Alport Chemical Corp. Brooklyn NY 

Wolverine Tube Division Detroit MI 

Wyckoff Drawn Steel Co. Chicago IL 

Wykoff Steel Co. Newark NJ 

Y-12 Plant Oak Ridge TN 

Yucca Mountain Site Characterization Project Yucca Mountain NV 

Carborundum Company Niagara Falls NY 

Oak Ridge Thermal Diffusion Plant (S-50) Oak Ridge TN 

Westinghouse Nuclear Fuels Division Cheswick PA 

Tonopah Test Site 

North Las 

Vegas NV 

Ore Buying Station at Globe Globe AZ 

Green Sludge Plant Uraven CO 

Uranium Mill in Durango Durango CO 

Ore Buying Station at Grants Grants NM 

Ore Buying Station at Shiprock Shiprock NM 

Ore Buying Station at Edgemont Edgemont SD 

Ore Buying Station at Marysvale Marysvale UT 

Ore Buying Station at Moab Moab UT 

Ore Buying Station at Monticello Monticello UT 

Ore Buying Station at White Canyon White Canyon UT 
23 

Uranium Mill in Monticello Monticello UT 

Ore Buying Station at Crooks Gap Crooks Gap WY 

Ore Buying Station at Riverton Riverton WY 

General Electric -Ray Division Milwaukee WI 

Nevada Site Office No. Las Vegas NV 

High Energy Rate Forging (HERF) Facility Onard CA 

Mill at Moab Utah Moab UT 

Clinton Engineer Works (CEW) Oak Ridge TN 

Canoga Avenue Facility (Vanowen Building) Los Angeles CA 

De Soto Avenue Facility Los Angeles CA 

Downey Facility Los Angeles CA 

Kirtland Operations Office Albuquerque NM 

Ross Aviation Albuquerque NM 

Section E. Signatures 

Signature:_______________________________________ Date:________ 

Print Name: _____________________________________ 

Witness Signature: _______________________________ Date:________ 

Print Name: ______________________________________